Barrett v. Holmes was a United States Supreme Court case that addressed the issue of whether a state court could issue a writ of habeas corpus to a prisoner who had been convicted in a federal court. The case arose when a prisoner, John Barrett, was convicted in a federal court in the District of Columbia and sentenced to imprisonment. Barrett then sought a writ of habeas corpus from the Supreme Court of the District of Columbia, claiming that his conviction was unconstitutional. The Supreme Court of the District of Columbia granted the writ, and the United States government appealed to the Supreme Court of the United States. The Supreme Court of the United States held that the Supreme Court of the District of Columbia did not have the authority to issue a writ of habeas corpus to a prisoner convicted in a federal court. The Court reasoned that the writ of habeas corpus was a remedy available only to prisoners convicted in state courts, and that the federal government had exclusive jurisdiction over federal criminal cases. The Court also noted that the writ of habeas corpus was a remedy available only to prisoners who had exhausted all other remedies available to them. The Court's decision in Barrett v. Holmes established that state courts do not have the authority to issue writs of habeas corpus to prisoners convicted in federal courts. The decision also established that the writ of habeas corpus is a remedy available only to prisoners who have exhausted all other remedies available to them.

Justice Field delivered the dissenting opinion in Barrett v. Holmes, arguing that the majority's decision was wrongfully based on a misapplication of state law. He argued that under Mississippi law, which governed this case, an executor had no authority to sell land belonging to an estate without first obtaining permission from the court or other legal authority. The majority held that such permission was not necessary because it believed there were sufficient facts indicating consent by all interested parties; however, Justice Field disagreed and argued that even if consent could be inferred from these facts, it would still be insufficient as a matter of law since only a court order could authorize such action. Furthermore, he noted how allowing executors to make decisions about selling real property without proper authorization would lead to potential abuse and confusion among heirs who might have conflicting interests in the estate’s assets. Therefore he concluded that any sale made by an executor should require prior approval from either a court or some other legally authorized body before being considered valid under Mississippi law.